COMMENT TO FDA
In Reference to Docket No. 99N-4282
Label Genetically Engineered Foods and Food Ingredients
July 7, 2000
The Organic Trade Association is a membership-based business association, composed of over 1000 members, and representing all sectors of the organic industry throughout North America. OTA's mission is to encourage global sustainability through promoting and protecting the growth of diverse organic trade. As part of that mission, OTA requests that FDA require the labeling of foods containing genetically engineered organisms or their products.
Organic agriculture has existed, and its producers have been proud to label their products, for decades. Unless these experimental and fundamentally different genetically engineered products are also labeled, substantial burdens are placed on the organic industry. First, there is the burden of avoiding unintentional contamination from these synthetic products—at every step from the seed to the store. Second, there is the burden of either performing complicated and expensive tests on a wide variety of ingredients in processing and manufacturing, or trying to obtain affidavits of non-GMO origin from suppliers, to ensure clean product. Labeling should apply to all genetically engineered products destined for food—not only raw agricultural products but processing enzymes, yeasts, extractions, and other genetically engineered minor ingredients as well.
FDA should take this step because Americans want to know what they are eating, and they have a right to that knowledge. People are concerned about the food they eat—some want food that is grown in an ecologically healthy way, others want food that is prepared according to religious principles, and still others want food that does not contain animal products. Until recently, consumers could buy organic, kosher, or vegetarian, and be assured that they were getting nothing more and nothing less than what was advertised. Now, due to the new and truly dramatic development of genetic engineering, consumers are getting more than they know, and as polls have shown, more than they want.
The public interest lies in more knowledge, not less. The businesses creating genetically engineered products are free to make their claims, but these claims, along with GMO-industry tests, cannot be taken as scientific proof of anything. Any unintended side-effects of these new organisms must be discovered and eliminated. Until a thorough and independent testing program is completed, the public interest is not served by denying the public the choice of eating non-genetically engineered food.
This is especially important for the organic industry. Organic producers take great care to offer customers a quality product without the use of synthetic processing materials or ingredients. Now, producers are faced with not only the problem of contamination in the field but, more fundamentally, even the inability to be sure they are choosing non-genetically engineered minor ingredients—because they are not labeled. The burden of labeling should not be on the producers of conventional or organic food. They are not the ones introducing this new technology. The burden should be on the companies seeking to market these novel products.
There are also clear reasons why labeling must be attached to genetically engineered foods, rather than those which are not. First, there are many foods which do not have genetically engineered varieties to begin with. To label these “non-GE” would be misleading and very confusing for consumers. Requiring a “non-GE” label would also be an unjustifiable burden on all the companies that have not changed their products in any way. The burden of labeling should be on the companies introducing experimental products.
In light of the discovery of conflicting opinions within FDA regarding the safety of genetically engineered foods, OTA also believes that it is time to stop automatically regarding genetically engineered foods as substantially equivalent to their closest natural counterpart. Nutritional equivalence has yet to be demonstrated, and there may be significant variability. Likewise, because this technology is experimental, OTA opposes the practice of considering genetically engineered foods as “generally regarded as safe.”
OTA urges FDA to enact these policies immediately. As proper scientific studies begin to be conducted—those that are both objective and longitudinal—consumers will learn more about both the health and the ecological effects of this infant and radically different technology. But FDA must act in the meantime to ensure that those citizens who do not wish to eat experimental, altered foods can choose not to.
Without the labeling of genetically engineered foods, consumers will have to contend with not knowing whether they foods they eat are what they believe they are. On the other hand, with clear labeling, the companies promoting these new products will be able to both display their pride in their products and enjoy the opportunity to win consumers to their menu.
Will you deny all Americans the right to that choice?
